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U.S.–Germany Inheritance Scenario

U.S. Person Inherits from Germany

An inheritance from Germany can create German inheritance-tax exposure, U.S. information-reporting obligations and important basis and valuation questions for the U.S. beneficiary. The result depends on the decedent, the heir, the assets transferred and the documentation available.

Overview

The inheritance may be taxed in Germany even when the heir lives in the U.S.

German inheritance tax does not depend only on where the heir lives. The residence and status of the decedent and beneficiary, the location and type of assets and the U.S.–Germany estate and gift tax treaty can all affect the result.

On the U.S. side, receiving an inheritance generally raises different issues from making a taxable transfer. Information reporting, basis, subsequent income and later sales often matter more than U.S. estate or gift tax at the moment of receipt.

German tax perspective

The German TaxRep counterpart focuses on German inheritance-tax liability, exemptions, valuation, notification and filing obligations.

Open German perspective

German Inheritance Tax

German tax exposure depends on personal and asset-based connecting factors

German decedent

If the decedent had a relevant German connection, German inheritance tax can extend beyond assets physically located in Germany.

GermanyInheritance tax

German-situs assets

German real estate and certain business interests can remain relevant even where the beneficiary is resident in the United States.

Real estateBusiness assets

Allowances and relationship

German inheritance-tax allowances and rates depend in part on the beneficiary's relationship to the decedent and other statutory factors.

AllowancesFamily

U.S. Reporting

Receiving the inheritance can create U.S. information-reporting obligations

Form 3520

A U.S. person receiving a sufficiently large foreign inheritance may have Form 3520 reporting even where no U.S. tax is due on receipt.

Foreign accounts

If inherited cash or securities remain in German accounts, FBAR or Form 8938 reporting can become relevant depending on the facts.

Foreign companies

Inherited GmbH shares can create separate U.S. foreign-company reporting and shareholder-tax issues after the transfer.

Future income

Dividends, rent, interest and capital gains generated after the inheritance may be taxable in the U.S. and potentially in Germany as well.

Asset Types

Inherited assets can create different follow-up obligations

German property inherited by a U.S. person

German inheritance tax, ownership, rental income, depreciation and later sale planning.

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German GmbH shares inherited by a U.S. person

German transfer tax, valuation and subsequent U.S. foreign-company reporting.

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Form 3520 for foreign inheritances

When a foreign inheritance can create U.S. information-reporting obligations.

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German valuation vs. U.S. basis

Transfer-tax values and U.S. income-tax basis should be documented separately.

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U.S.–Germany estate and gift tax treaty

Treaty rules can affect domicile, situs allocation and relief where both systems apply.

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Inheritance tax credit coordination

German and U.S. tax assessments, payment evidence and timing may matter where double-tax relief is claimed.

Read guide

Documents & Planning

Preserve the inheritance file before assets are sold or moved

Will and probate documents

Keep the will, probate documents, executor records and evidence of the beneficiary's entitlement.

Valuation records

Retain appraisals, account statements and company valuations from the relevant inheritance date.

German tax assessments

Keep German inheritance-tax returns, assessments and proof of tax paid for later credit analysis.

Basis documentation

Do not assume that the German inheritance-tax value automatically becomes the U.S. income-tax basis.

Account transfers

Review U.S. reporting before moving inherited cash or securities between German and U.S. accounts.

Future sale

Before selling inherited property or shares, coordinate basis, currency and source-country taxation.

U.S.–Germany Inheritance Tax

Received an inheritance from Germany?

We can coordinate German inheritance tax, U.S. reporting, treaty treatment, valuation and basis documentation, foreign accounts and later taxation of the inherited assets.

Discuss your inheritance